Case Summary (G.R. No. 189293)
Charges and Legal Proceedings
The accused-appellant, Vicente Candellada, faced a Criminal Case, specifically for attempted rape occurring on December 28, 2004, and subsequently for eight counts of consummated rape alleged to have occurred between May 30, 2004, and December 25, 2004. During the arraignment on May 17, 2005, he pleaded not guilty. The prosecution's case relied on the testimony of the victim, [AAA], and supporting witnesses, including a health officer and police officers. The defense consisted mainly of the accused's testimony, asserting innocence and presenting an alibi.
Testimony and Evidence
The victim, [AAA], recounted numerous instances of rape at the hands of her father, detailing the violence and threats she endured. This included testimony about being threatened with a knife during the acts. A key witness, Dr. Jovenal Magtagad, examined [AAA] post-incident, noting physical injuries consistent with assault but did not initially document allegations of rape. Additionally, the defense's alibi claimed he was already incarcerated at the time of the last reported incident, which was contested by prosecution witnesses.
Trial Court’s Decision
The Regional Trial Court issued a consolidated decision on December 23, 2005, acquitting Candellada of attempted rape due to insufficient evidence but found him guilty of eight counts of rape. It determined that the evidence established guilt beyond a reasonable doubt for these counts, resulting in the imposition of the death penalty and damages to the victim.
Court of Appeals Review
Candellada appealed the trial court's findings to the Court of Appeals, claiming insufficiency of evidence. The Appellate Court affirmed the trial court's conviction but modified the sentencing from death to reclusion perpetua without parole eligibility, aligning with Republic Act No. 9346, which prohibits the imposition of the death penalty in the Philippines. Additionally, it mandated higher awards of damages for the victim.
Legal Standards Applied
In deciding the case, the Court adhered to the standards set forth in the Revised Penal Code regarding the prosecution of rape. Under Articles 266-A and 266-B, the conviction for qualified rape requires the determination of several key elements, including the relationship between the victim and the offender, which in this case was established as the victim was a minor and her father was the accused.
Credibility of Testimony
The Court discussed the credibility of the victim's testimony, affirming the principle that the testimony of a victim can suffice for conviction if credible and consistent. It underscored that the trial court'
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Case Overview
- This case involves the appeal of Vicente Candellada against the Decision of the Court of Appeals dated April 29, 2009, which upheld the conviction of Candellada for eight counts of rape and acquitted him of attempted rape.
- The charges stemmed from allegations made by his minor daughter, referred to as AAA, regarding incidents occurring between May and December of 2004.
Charges and Information
- Candellada was charged with attempted rape in Criminal Case No. 118-07-2005, alleging he attempted to have sexual intercourse with AAA on December 28, 2004, while under the influence of liquor.
- Additionally, he faced eight counts of consummated rape (Criminal Case Nos. 159-07-2005 to 166-07-2005) for incidents occurring on specific dates: May 30, June 2, June 12, July 10, August 13, November 5, December 15, and December 25, 2004.
- The charges cited violations of R.A. 8353 (Anti-Rape Law) and R.A. 7610 (Anti-Child Abuse Law).
Background of the Parties
- AAA, the complainant, was born on January 10, 1990, and was the second daughter of Candellada and his deceased first wife.
- At the time of the alleged rapes, AAA was 14 years old and lived with Candellada and his second wife in Lanao del Norte.
Prosecution's Case
- The prosecution presented key witnesses:
- Dr. Jovenal Magtagad, who examined AAA and noted physical injuries.
- AAA, who testified about the assaults and her pregnancy.
- Elsie Gemina, who observed the living conditions and behavior of Candellada and AAA.
- Senior Police Officer Rosa Bastigue, who investigated the case.
- Evidence included affidavits